Subject: File No. 4-619
From: Carina Dietman

August 14, 2012

Chairman Schapiro
U.S. Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549-1090

Dear Chairman Schapiro:

I am a trust officer specializing in qualified defined contribution plans such as 401(k) plans.

Money market investments means stability (no price change fluctuation) to the average plan participant who struggles with the ups and downs of the market. Adding NAV and redemption restrictions will only increase the cost of the investment at a time when the investment bears little to no return and when retirement plan vendors attempting to reduce costs to provide plan participants with greater retirement savings.

Adding redemption requirements also complicates the investment for the average participant and again adds cost due to the need to monitor the investment holding period. It may also impede a Plan Sponsor's ability to transition the retirement plan between providers.

It is important to understand the potential unintended consequences the proposal may have. Less can be more.


Carina Dietman